Good analysis. Very disappointing that IMO's MEPC committee took no action to reduce carbon emissions from shipping and that it actually moved backward. By not taking any action on the major GHG/climate change issue, the IMO risks ceding control to others and without meaningful improvement that outcome is deserved. While that deferment wasn't a complete surprise, more troubling in many ways was the proactive action the committee took in giving preliminary approval to a little noticed amendment to the North American ECA waiving the new fuel requirements for steamships. This action is inconsistent with the MEPC's mission and the clear need for positive environmental change. If and when any final action on that is taken and focused on, it will add to the case that control of shipping emissions is better left to other governmental entities who will take constructive action.

Steamships are the dirtiest vessels afloat and giving them a pass on the new fuel standards is ill-conceived and a step backwards. The submission by the US contained no detailed data and implied that the emissions effect would be deminimous and consistent with the "fraction of a percent" that steamships represent of the world fleet. That implication, however, is inaccurate because these steamships are spending much of their time in short coastal voyages within the North American ECA and they use more fuel than non steam-powered vessels. Taking all the factors into account, my detailed analysis shows that these steamships represent from 7.9% to 17.7% of the total sulfur emissions by vessels in the North American ECA. Using the same morbidity data contained in the original ECA application, backtracking on that amount of sulfur emissions will translate into from 441 to 990 premature deaths annually in the US and Canada along with tens of thousands of other respiratory ailments. This steamship waiver represents a material change to a previously well-thought-out North American ECA framework. In addition to materially increasing toxic sulfur emissions, when you consider the black carbon in the dirty fuel, this waiver will make the climate change effect from vessels even worse. That is an ironic outcome of a meeting that deferred action on the GHG/climate change issue.

With only 1 of 166 delegates showing support at last week's meeting, this waiver hardly has strong backing. Prior to any final vote, it seems that it is incumbent on the US to provide detailed data similar to the original ECA application that also highlights the human health effects if this waiver is implemented. Their analysis of the adverse health effects may differ somewhat from mine, but I'm confident it too would show that this steamship waiver would be a material change in sulfur emissions compared to the original ECA application. I'm hopeful that with this new information before them, some MEPC delegates will object to this steamship waiver when it next comes up for a vote and it will be defeated as any rational analysis says it should. My analysis shows that the sulfur emissions from EACH steamship can be linked with from 9 to 16 premature deaths each year. How can anybody rationally say that the most toxic vessels afloat, by far, should be given a pass to continue burning fuel with 3,000 times as much sulfur as in other fuels? With apologies to Ralph Nader, these steamships are "unsafe at any speed" for human health when they are using dirty fuel. If this steamship waiver receives the final approval of MEPC and the IMO, it will reflect poorly on those groups environmental stewardship and be a clear indication that action, even unilateral action, by other governmental entities is sorely needed.

The vessel sulfur emissions issue is one of the biggest readily changeable environmental issues today. Some 60,000 lives worldwide would be saved with a switch to cleaner fuel. Customers of shipping companies that have stated environmental initiatives should encourage shipping companies to switch ahead of the IMO timeline by rewarding them with more business. Now that the human health consequences of these toxic sulfur emissions are known, if market based incentives can be utilized to hasten the transition, so much the better. It makes no sense for the MEPC to be associated with any waiver or amendment that will slow down an already lengthy transition period. SEA/Change (Sulfur Emissions Awareness/Change) is focused on increasing the awareness of this issue with the belief that once someone is aware of all the relevant facts, the path they should take will be obvious.

John McCown
SEA/Change
jdmnyc@panix.com